OAKTON GLOBAL TECHNOLOGY SERVICES CENTRE (I) PRIVATE LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(2), HYDERABAD

ITA 32/HYD/2019Status: DisposedITAT Hyderabad16 April 2025AY 2014-15Bench: SHRI VIJAY PAL RAO (Vice President), SHRI MADHUSUDAN SAWDIA (Accountant Member)35 pages
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What did the Tribunal hold?

The Tribunal remanded the issue of excluding certain companies from the comparables list to the AO/TPO for verification of functional comparability. It also directed the AO/TPO to follow the DRP's directions regarding another comparable company and provided specific guidance for benchmarking interest on trade receivables.

What were the facts?

The assessee, engaged in software development services, appealed against the final assessment order which included upward adjustments to the arm's length price (ALP) of international transactions. The adjustments were made based on the directions of the Dispute Resolution Panel (DRP).

What were the issues?

The key issues involved the selection of comparable companies for transfer pricing analysis, benchmarking of interest on trade receivables, and the application of adjustments for provisions for doubtful debts and working capital.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 92CA(3),Section 144C(5),Section 92B,Section 234B,Section 234C,Section 271AA,Section 271BA

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Income Tax Appellate Tribunal, Hyderabad ‘A’ Bench, Hyderabad

Before: SHRI VIJAY PAL RAO & SHRI MADHUSUDAN SAWDIA

Hearing: 27/02/2025

PER MADHUSUDAN SAWDIA, A.M. : These appeals are filed by M/s. Oakton Global Technology Services Centre (India) Private Limited (“the assessee”), feeling aggrieved with the final assessment order of Learned Assessing Officer ("Ld. AO") passed u/s.143(3) r.w.s. 92CA(3) r.w.s. 144C(5) of the Income Tax Act, 1961 ('the Act'), as per the direction of Learned Dispute Resolution Panel, Bangalore (“Ld. DRP”) on 05.10.2017 & 26.10.2018 for A.Ys. 2013-14 & 2014-15 respectively. Since these appeals are inter-related, th

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